Smilecookie Company with the personal information protection that the information and communication service providers must comply with in the related laws, such as the Privacy Act, the Act on Promotion of Information and Communication Network Utilization, and the Act on Information Protection.

1. What is the privacy policy?

The Privacy Policy provides information on the personal information lifecycle, such as what personal information Smilecooki collects, how to use the collected information, who it shares with, and when and how it destroys personal information that has been achieved for the purpose of use

In addition, we will tell you what rights the users have in their personal information, how they can exercise it, and who can contact and receive help to prevent damages in the event of personal information violation.

In addition to the lifecycle of the user’s personal information, the Privacy Policy provides game services and related services (hereinafter referred to as “services”) to ensure the user’s right to self-determination of personal information by defining the relationship between the users’ rights and obligations.

2. Personal information collected

Smilecookies collect the following personal information:

Users receive their nicknames, membership numbers, friend lists, and profile photos from the users used by the services of the platform operator (e.g., Kakao) from the platform operator (e.g., Kakao), and the platform service provider provides such information to the platform operator after obtaining consent for the provision of personal information under the Information and Communication Network Act when the users use the service.

In addition to the personal information provided by the platform operator, or during the course of service use, the user collects service use records, access logs, bad usage records, carrier information, OS information and device information, advertising identifiers, language information, and payment records.

In addition, the date of birth (or age) is collected after obtaining additional consent from the users during the service use process.In this case, if the user is under the age of 14 years old, the name of the legal representative, date of birth, carrier, and cell phone number shall be collected additionally.

In addition, additional information may be collected in the event that the user participates in or applies for a prize in the service event or during the service use inquiry. In such a case, the user is notified of the personal information collected, the purpose of use, and the period of storage and collected separately.

Smilecookies collect personal information in the following ways:

Smilecookies collect your personal information through service applications, written, fax, customer center counseling (telephone or e-mail), event participation, delivery from affiliates, and creation information collection tools.

3. Use of personal information collected

Smilecookie uses the personal information collected as follows.

Personal information is used for invitation of friends, recommendation of friends, purchase of paid contents (item), payment or gift, viewing game rankings, playing games with other users, and providing notification services.

In addition, personal information is used to prevent and prevent acts that interfere with the operation of the service, such as checking the intention to sign up or withdraw, identifying and identifying users based on service use, and imposing restrictions on the use of the service, which violate the terms and conditions or the service policy, and to preserve records for dispute settlement, handling complaints, and conveying notices.

In addition, personal information is used to analyze service usage records and provide customized services (including advertisements), provide services according to demographic characteristics and publish customized advertisements, develop/ update services, provide events or provide advertising information.

4. Providing personal information and storing it overseas

Smilecookie uses the user’s personal information within the scope of collection and utilization. Without the user’s prior consent, the user does not use or provide the user’s personal information beyond the scope. However, personal information can be used or provided with care in the following cases:

Smilecookie informs the user of who the partner is collecting/providing prior to personal information collection or provision, what information is required, and how long they keep it. If the user does not agree, it does not collect or provide the user.

Smilecookies can be provided if there is a special provision in the law or if the investigative agency requires them in accordance with the procedures and methods set forth in the law for investigation purposes.

5. Destruction of personal information

Smilecookie, in principle, destroys the user’s personal information without delay when the user withdraws from the service. However, if the user obtains separate consent for the period of personal information storage or if the relevant law specifies the storage obligation for a certain period, the user shall keep the information for the period and discard it without delay. In addition, personal information of users who have not used the service for one year is separately stored in accordance with the Act on Promotion of Information and Communication Network Utilization and Information Protection, and personal information stored separately is discarded without delay after five years of storage.

Smilecookie is destroyed in such a way that it is not possible to recover or regenerate personal information that has been collected and used for personal information such as the user’s withdrawal from service, termination of service, or arrival of storage period. If it is possible to crush printed materials or other forms, physically shred or incinerate them so that they cannot be reassembled. Personal information stored in electronic file form shall be destroyed using technical methods (e.g., low level format, wiping, etc.).

In the following cases, the relevant laws stipulate the storage of personal information for a certain period of time.

Smilecookie keeps personal information for a period specified by relevant laws and is not used for any other purpose than storage purposes.

[Act on Consumer Protection in Electronic Commerce, etc.]

Records on contract or subscription withdrawal, etc. : Storage for 5 years

Records on Payment and Supply of Goods: Storage for 5 years

Records on consumer complaint or dispute handling: Storage for 3 years

[Telecommunications Secrets Protection Act]

Connection record: Storage for 3 months

6. and legal agent’s rights and how that event.

The users or legal representatives can inquire or modify personal information of themselves or children under the age of 14 through the platform operator or app store operator at any time. In addition, in the configuration of the service application, the platform operator can view the information provided to Smilecooky, and use “retirement” to withdraw consent to collect and use personal information (including user information collected by Smilecooky). The users or children under the age of 14 shall be corrected using the member information modification function provided by the platform operator or app store operator. In the case of request for correction of personal information errors, personal information shall not be used or provided until correction is completed.

Automatic collection the installation of devices and personal information operations and matters concerning the refusal.

7. Smiley cookie for the services not use the (cookie) cookies.

[Cookie?]

Cookies are stored on your computer’s hard disk as tiny text files sent to your browser by the server used to operate the website. If the user visits the website afterwards, the website server is used to read the contents of cookies stored on the user’s hard disk to maintain the user’s preferences and provide customized services.

Cookies do not actively/automatically collect information identifying individuals, and users may refuse to save or delete these cookies at any time. However, it may not be possible to use all or part of the service if the cookie is refused to be saved.

To specify whether to allow cookies to be installed (for Internet Explorer): Select “Internet Options” from the “Tools” menu ⇒ Click on “Privacy tab” ⇒ Set the level of personal information handling

8. Activities and efforts to protect personal information

Smilecookie makes the following efforts to prevent personal information from being lost, stolen, leaked, tampered with or damaged in handling the user’s personal information.

The user’s personal information is secured using a security system in accordance with the relevant laws and internal policies.

We are taking steps to prevent damage caused by computer viruses by using a vaccine program. The vaccine program is updated periodically, and if a virus appears suddenly, it is applied immediately after the vaccine is released to prevent personal information from being compromised.

The company safely stores and manages the personal information of users and adopts a security system that enables the safe transmission of personal information on the network.

In order to prevent leakage of users’ personal information, such as hacking, the company uses a system that blocks intrusions from outside the company and always monitors intrusions from outside.

POSCO E&C has prepared systematic criteria for the right to create, change, and access passwords for database systems that store personal information and systems that process personal information so that employees in charge can comply with them.

The Act strictly limits employees who handle personal information to one person who performs personal information management and business personal information, and allows them to protect their personal information through regular training for the

9. Personal Information Protection Officer Information

Smilecookie designates the person in charge of personal information protection as follows to handle the user’s personal information inquiries and complaints.

[Personal Information Management Officer/Responsible Officer]

Name: Park Suk Soon

Member and position: Executive in charge of foreign cooperation

Phone: +82-10-9678-2803

Email: support@smilecookie.com

If you need to report or discuss any other personal information violation, please contact the organization below.

Personal Information Violation Reporting Center(privacy.kisa.or.kr / 118 without a National Code

Cyber Crime Division of the Supreme Public Prosecutor’s Office(www.spo.go.kr / 1301) without a national number

The National Police Agency’s Cybersecurity Bureau(www.cyber.go.kr / 182)

Personal Information Dispute Coordinating Committee(www.kopico.go.kr/ 1833-6972)

This Privacy Policy is in effect on October 31, 2019.